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Williams v. Wright

927 F.2d 1540 (1991)

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Williams v. Wright

United States Court of Appeals for the Eleventh Circuit
927 F.2d 1540 (1991)

Facts

James Williams (plaintiff) had worked for Wright Pest Control Company (WPCC) (defendant) since 1947. On October 23, 1981, WPCC’s president, Fred Wright (defendant), gave Williams a letter detailing Williams’s transition into retirement. The letter indicated that as of January 1, 1982, WPCC would issue Williams a $500 check each month. WPCC also agreed to provide Williams benefits that included paying life-insurance and medical-insurance premiums for Williams and his wife. The funding for these benefits came from WPCC’s general assets. The letter stated that the benefits would continue until Williams’s death or until Williams no longer had a need for them. Wright and WPCC began treating Williams as retired following the letter and characterized money paid to Williams pursuant to the letter as retirement pay. In late 1985, WPCC was dissolved and sold to another company, and WPCC terminated Williams’s benefits. Williams subsequently sued WPCC and Wright, alleging violations of the Employee Retirement Income Security Act of 1974 (ERISA). The district court granted summary judgment for WPCC and Wright, concluding that the benefits arrangement in the 1981 letter was not a plan, fund, or program covered by ERISA and was instead an employment contract that provided for post-retirement compensation. Williams appealed.

Rule of Law

Issue

Holding and Reasoning (Anderson, J.)

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